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Fitch: Medicaid Block Grants, MFAR Threaten States, Providers

Medicaid block grants and the proposed Medicaid fiscal accountability regulation (MFAR) pose new financial threats to providers and states, according to Fitch Ratings, the financial rating company.

MFAR poses the greater threat, Fitch believes, noting in a new analysis that it could

…reduce total Medicaid spending nationally by $37 billion and $44 billion annually…and by $23 billion to $30 billion for hospitals alone.  States, and to some extent providers, would respond to MFAR’s implementation with measures to mitigate the negative fiscal implications.

Block grants, through what has been named the Healthy Adult Opportunity program, also pose a threat, with Fitch explaining that

Capping federal Medicaid contributions, even for a subset of beneficiaries, poses risks to state budgets and those entities reliant on state funding, including local governments and providers.  States would need to find revenue or cost savings, either in Medicaid or elsewhere, to offset reduced federal contributions.

Because private safety-net hospitals care for more Medicaid patients than the typical hospital, both proposed policy changes have a potentially greater impact on them.

Last month NASH conveyed its opposition to the proposed MFAR regulation in a formal comment letter to the Centers for Medicare & Medicaid Services in response to the regulation’s publication late last year.  While NASH has not commented publicly about the Healthy Adult Opportunity program, it has long been concerned about a block grant approach to Medicaid funding, writing in its 2019 advocacy agenda that

Block grants, whether based on individual states’ Medicaid enrollment or on their past Medicaid spending, could impose unreasonable limits on Medicaid spending that could potentially leave private safety-net hospitals unreimbursed for care they provide to legitimately eligible individuals. NASH will work to ensure that any new approach that involves Medicaid block grant continues to give states the ability to pay safety-net hospitals adequately for the essential services they provide to the low-income residents of the communities in which those hospitals are located.

Learn more about the potential impact of the proposed Medicaid fiscal accountability regulation and Medicaid block grants in the Fitch Ratings analysis “Fitch Rtgs: Medicaid Changes Will Affect States, NFP Healthcare Providers.”

Verma Responds to Medicaid Block Grant Critics

Last week the Trump administration unveiled its Healthy Adult Opportunity program, a new, optional, already-controversial approach to structuring state Medicaid programs.

Ever since, the program – essentially, Medicaid block grants – has been the subject of criticism from many public officials and health care stakeholders.

Now, Centers for Medicare & Medicaid Services administrator Seema Verma, who oversaw the development of Healthy Adult Opportunity, has responded to the program’s critics in an op-ed piece published in the Washington Post.  See her commentary “No, the Trump administration is not cutting Medicaid.

Health Care Groups Rebel Against Proposed Federal Regulation, Program

The administration’s proposed Medicaid fiscal accountability regulation and its guidance encouraging states to implement Medicaid block grants have incurred widespread opposition among a variety of health care groups.

The Medicaid fiscal accountability regulation would, if adopted, impose new restrictions on how states raise their share of their Medicaid spending, potentially limiting state participation in Medicaid or necessitating tax increases to fill the funding gap if long-accepted financing tools are no longer available to them.

The Medicaid block grant guidance offers states a blueprint for curtailing their Medicaid costs by imposing limits on that spending that they negotiate with the federal government.

Numerous health care groups have expressed reservations or direct opposition to one or both of the proposals.  Among them:

  • AARP
  • America’s Essential Hospitals
  • America’s Health Insurance Plans
  • American College of Emergency Physicians
  • American Health Care Association
  • American Hospital Association
  • American Medical Association
  • Association for Community Affiliated Plans
  • Association of American Medical Colleges
  • Coalition of Long-Term Acute-Care Hospitals
  • LeadingAge
  • National Association of State Budget Officers
  • National Association of Medicaid Directors
  • National Continuing Care Residents Association
  • National Governors Association
  • Private Essential Access Community Hospitals
  • Safety-Net Association of Pennsylvania

NASH is among the many that submitted formal comment letters in response to the proposed Medicaid fiscal accountability regulation; see NASH’s letter here.

Learn more about why these groups object to these two new policy developments in articles in Axios (“A little-noticed Medicaid proposal could have huge consequences”), Bloomberg Law (“Trump Plan to Tame State Medicaid Finance Schemes Sees Pushback”), Health Affairs (“Proposed Rules On Medicaid Financing Miss Mark And Threaten Access”), Healthcare Dive (“Payers, providers urge CMS to scrap rule targeting supplemental Medicaid payments”), Healthcare Finance News (“Providers, payers, others speak out against federal proposals for Medicaid funding”), McKnight’s Long-Term Care News (“Providers rally against proposed Medicaid supplemental payment rules that threaten ‘major financial burdens’”), McKnight’s Senior Living (“CMS proposal would be ‘major financial burden’ for CCRCs, residents, organizations say”),  and U.S. News & World Report (“Governors Warn Trump Rule Could Lead to Big Medicaid Cuts”)

Health Care Groups Rebel Against Proposed Federal Regulation, Program

The administration’s proposed Medicaid fiscal accountability regulation and its guidance encouraging states to implement Medicaid block grants has incurred widespread opposition among a variety of health care groups.

The Medicaid fiscal accountability regulation would, if adopted, impose new restrictions on how states raise their share of their Medicaid spending, potentially limiting state participation in Medicaid or necessitating tax increases to fill the funding gap if long-accepted financing tools are no longer available to them.

The Medicaid block grant guidance offers states a blueprint for curtailing their Medicaid costs by imposing limits on that spending that they negotiate with the federal government.

Numerous health care groups have expressed reservations or direct opposition to one or both of the proposals.  Among them:

  • AARP
  • America’s Essential Hospitals
  • America’s Health Insurance Plans
  • American College of Emergency Physicians
  • American Health Care Association
  • American Hospital Association
  • American Medical Association
  • Association for Community Affiliated Plans
  • Association of American Medical Colleges
  • Coalition of Long-Term Acute-Care Hospitals
  • LeadingAge
  • National Alliance of Safety-Net Hospitals
  • National Association of State Budget Officers
  • National Association of Medicaid Directors
  • National Continuing Care Residents Association
  • National Governors Association
  • Private Essential Access Community Hospitals

Among the groups submitting formal comment letters to the Centers for Medicare & Medicaid Services in response to the proposed Medicaid fiscal accountability regulation was the National Alliance of Safety-Net Hospitals.  See NASH’s letter here.

Learn more about why these groups object to these two new policy developments in articles in Axios (“A little-noticed Medicaid proposal could have huge consequences”), Bloomberg Law (“Trump Plan to Tame State Medicaid Finance Schemes Sees Pushback”), Health Affairs (“Proposed Rules On Medicaid Financing Miss Mark And Threaten Access”), Healthcare Dive (“Payers, providers urge CMS to scrap rule targeting supplemental Medicaid payments”), Healthcare Finance News (“Providers, payers, others speak out against federal proposals for Medicaid funding”), McKnight’s Long-Term Care News (“Providers rally against proposed Medicaid supplemental payment rules that threaten ‘major financial burdens’”), McKnight’s Senior Living (“CMS proposal would be ‘major financial burden’ for CCRCs, residents, organizations say”),  and U.S. News & World Report (“Governors Warn Trump Rule Could Lead to Big Medicaid Cuts

Implications of Medicaid Block Grants

States will be able to pursue new Medicaid block grants under guidance recently sent by federal regulators to state Medicaid directors.

But what does that mean?

In a new article, the Commonwealth Fund examines how the Centers for Medicare & Medicaid Services’ Medicaid block grants will work (for states that choose to pursue them; they are not mandatory), the new flexibility block grants will give states, and how the new approach will give states some relief from CMS oversight and delivery system requirements.

Because private safety-net hospitals care for more Medicaid patients than the typical hospital, such a major change in Medicaid policy has a potentially greater impact on them.

Learn more from the Commonwealth Fund article “What Does New Block Grant Guidance Mean for the Medicaid Program?” and by going directly to the source:  the guidance letter CMS sent to state Medicaid directors explaining in detail how Medicaid block grants will work.

CMS Introduces New Approach to Medicaid Block Grants

States would be able to convert part of their Medicaid programs into block grants under a new program introduced by the federal government.

The program, which the Centers for Medicare & Medicaid Services calls “Healthy Adult Opportunity,” would encompass services only for adults under the age of 65 who are not eligible for Medicaid because of disability or the need for long-term care, services, and supports and who are not otherwise eligible for the pre-Affordable Care Act Medicaid program.

Under the program, states can develop either a total expenses model or per enrollee model for their block grants and would have expanded opportunities to introduce co-pays and deductibles, impose work requirements, expand eligibility criteria, and waive retroactive coverage and hospital presumptive eligibility requirements.  To save on the cost of prescription drugs, they would be empowered to implement limited drug formularies.

The new program appears to be targeting states that did not expand their Medicaid programs under the Affordable Care Act.  It also appears to be CMS’s attempt to introduce the block grant concept in a limited way in the hope that it will be successful and lead to demand to expand block grants to the entire Medicaid program and not just the Medicaid expansion population.

In the past NASH has viewed Medicaid block grants with a degree of skepticism, maintaining that its possible support or opposition to them would be based on how a block grant program is structured and how new block grants might affect the ability of private safety-net hospitals to serve their communities.

Learn more about CMS’s new Healthy Adult Opportunity program in this CMS news release, this fact sheet, and a letter the agency sent to the nation’s state Medicaid directors.

 

Medicaid Block Grants Hit Bump in Road

The drive toward encouraging states to implement Medicaid block grants hit a bump in the road last week when the formal guidance for states that Centers for Medicare & Medicaid Services administrator Seema Verma suggested was imminent apparently became not-so imminent.

At the time Verma spoke, draft guidance from CMS to the states was under review by the federal Office of Management and Budget.  Last week, however, CMS withdrew that draft, which also was to address state Medicaid per capita cap programs.

The bump in the road does not, however, appear to be more than a temporary detour.  While CMS has not explained why the draft was withdrawn, Verma indicated that the agency still intends to provide guidance to state on Medicaid block grants and per capita spending limits.

NASH has long had concerns about Medicaid block grants, writing in its 2019 advocacy agenda that

Block grants, whether based on individual states’ Medicaid enrollment or on their past Medicaid spending, could impose unreasonable limits on Medicaid spending that could potentially leave private safety-net hospitals unreimbursed for care they provide to legitimately eligible individuals. NASH will work to ensure that any new approach that involves Medicaid block grant continues to give states the ability to pay safety-net hospitals adequately for the essential services they provide to the low-income residents of the communities in which those hospitals are located.

Learn more from the McKnight’s Long-Term Care News article “CMS withdraws proposed guidance on Medicaid block grants, funding caps.”

Groups Seek to Block Medicaid Block Grants

Do not permit states to adopt block grants for their Medicaid programs, more than two dozen groups have asked the Centers for Medicare & Medicaid Services.

A letter signed by the American Diabetes Association, American Heart Association, COPD Foundation, March of Dimes, United Way, and others states that

Simply put, block grants and per capita caps will reduce access to quality and affordable healthcare for patients with serious chronic health conditions and are therefore unacceptable to our organizations.

The letter explains that

Per capita caps and block grants are designed to reduce federal funding for Medicaid, forcing states to either make up the difference with their own funds or make cuts to their programs that would reduce access to care for the patients we represent…  States under a block grant or per capita cap would struggle to respond to changes in standards of care, such as the development of ground-breaking but expensive treatment, and would have a greater incentive to impose additional barriers for treatments to manage their overall costs…  Additionally, per capita caps and block grants would cut Medicaid most deeply when the need is greatest, as these financing structures do not protect either states or patients from financial risk as the result of an economic downturn or other expected event.

NASH has long been skeptical about the use of block grants in state Medicaid programs.  The organization’s advocacy agenda for 2019 explains that

Block grants, whether based on individual states’ Medicaid enrollment or on their past Medicaid spending, could impose unreasonable limits on Medicaid spending that could potentially leave private safety-net hospitals unreimbursed for care they provide to legitimately eligible individuals. NASH will work to ensure that any new approach that involves Medicaid block grant continues to give states the ability to pay safety-net hospitals adequately for the essential services they provide to the low-income residents of the communities in which those hospitals are located.

Learn more about the groups that signed this letter and their objections to Medicaid block grants and per capita caps by reading their letter to CMS.

HHS Talking to States About Medicaid Block Grants

In the absence of legislation to turn Medicaid into a block grant program, the U.S. Department of Health and Human Services is talking to some states about granting waivers that permit them – voluntarily – to turn their individual Medicaid programs into block grants.

HHS Secretary Alex Azar acknowledged this last week during a hearing of the Senate Finance Committee.  He did not disclose which states, or how many, with which HHS has had such discussions and he also noted that his staff is talking to state officials about waivers to permit them to adopt Medicaid per capita spending limits.

NASH has long been concerned about any effort to impose artificial limits on state Medicaid spending; such limits could be especially harmful to private safety-net hospitals because they care for so many Medicaid patients.  NASH’s most recent expression of this concern can be found in its 2019 advocacy agenda.

Learn more from the article “Trump health chief reveals talks with states on Medicaid block grants,” which can be found in the online publication The Hill.

Trump Budget Brings Bad News for Private Safety-Net Hospitals

The FY 2020 federal budget proposed by the Trump administration this week would bring pain for private safety-net hospitals if adopted.

Highlights of the proposed spending plan include:

  • More than $135 billion in cuts in Medicare uncompensated care payments (Medicare DSH) and Medicare bad debt reimbursement over the next 10 years.
  • Continued extension of Medicare site-neutral payment outpatient policies.
  • $48 billion in cuts in graduate medical education spending over the next 10 years.
  • $26 billion in new Medicaid disproportionate share (Medicaid DSH) cuts.
  • Repeal of the Affordable Care Act’s Medicaid expansion and all funding to pay for that expansion.
  • Support for legislation to introduce Medicaid block grants and limits on spending per recipient.
  • New restrictions on the 340B program.

Responsibility for adopting a budget rests with Congress, not the president, and this proposed budget is considered unlikely to gain much support in Congress.

As appropriate, NASH will engage in advocacy in support of the needs of the nation’s private safety-net hospitals.

Learn more about the administration’s proposed budget from numerous media reports or by going directly to the source:  fact sheets the White House has prepared offering budget highlights and the budget document itself.